Default Judgment Secured: Diedrichsen v. Schedule A Defendants

In April 2024, Erik Diedrichsen and Riverbend Resources, Inc. filed a patent infringement action in the Northern District of Illinois that concluded 587 days later with something relatively uncommon in patent litigation: a default judgment against every named defendant. The case, docketed as 1:24-cv-02773, closed on November 13, 2025, with the court awarding statutory damages against each defaulting defendant and releasing a $10,000 surety bond back to the plaintiffs.

This outcome reflects a growing enforcement pattern in intellectual property litigation — particularly the use of Schedule A complaints targeting anonymous or evasive online infringers. For patent attorneys, IP professionals, and R&D teams, this case offers a practical lens into the procedural mechanics of default judgment, the strategic logic behind Schedule A enforcement actions, and the risks companies face when they fail to engage in federal litigation.

Case Overview

The Parties

The Patent(s) and Product(s) at Issue

The specific patent numbers and accused products were not disclosed in the available case record. However, the use of a Schedule A defendant structure strongly suggests the alleged infringement involved consumer products sold through online marketplaces such as Amazon, eBay, Alibaba, or similar platforms — a pattern consistent with the Northern District of Illinois’s well-developed docket of such enforcement actions.

Legal Representation

The plaintiffs were represented by attorneys Benjamin Adam Campbell, Edward L. Bishop, Nicholas S. Lee, and Sameeul Haque of Bishop Diehl & Lee, Ltd. and Dickinson Wright PLLC — both recognized firms in intellectual property enforcement. No defense counsel appeared of record, consistent with the default judgment outcome.

Litigation Timeline and Procedural History

The case spanned 587 days from filing to closure, presided over by Judge Franklin U. Valderrama of the U.S. District Court for the Northern District of Illinois.

A notable procedural feature was the early issuance of a temporary restraining order (TRO), for which plaintiffs posted a $10,000 surety bond — standard practice in Schedule A cases where courts act quickly to freeze assets or enjoin ongoing infringement before defendants can dissipate proceeds or remove infringing listings. The bond’s release to plaintiffs upon case termination confirms the TRO served its intended purpose within the broader enforcement strategy.

The 587-day duration, while longer than some default proceedings, reflects the reality that even uncontested patent cases require proper service, notice periods, and procedural compliance before a court will enter judgment.

The Verdict & Legal Analysis

Outcome

Judge Valderrama granted the Plaintiffs’ Motion for Entry of Default and Default Judgment (Docket No. 85), entering a Default Judgment Order that awarded statutory damages on a per-defendant basis against each defaulting party. The precise per-defendant damage amounts are established in the court’s order but were not itemized in the summarized case record available here.

The $10,000 surety bond posted in connection with the TRO was released to plaintiffs or their counsel at Bishop Diehl & Lee, Ltd., and the civil case was formally terminated.

Verdict Cause Analysis

Default judgment in patent infringement actions arises when a defendant fails to answer, appear, or otherwise defend after being properly served. Under Federal Rule of Civil Procedure 55, the court may enter default and subsequently default judgment, accepting the well-pleaded allegations of the complaint as true.

In Schedule A patent cases, defendants frequently:

• Operate through anonymous seller accounts
• Reside outside U.S. jurisdiction
• Abandon accounts or dissolve entities upon receiving notice
• Strategically fail to appear to avoid discovery obligations

By failing to respond, each defendant effectively conceded the infringement allegations, allowing the court to proceed to damages without a merits trial. The statutory damages framework applied here provides plaintiffs with a predetermined range of recovery — often critical when actual damages are difficult to calculate or prove against anonymous infringers with opaque sales records.

Legal Significance

This case reinforces several important principles in patent enforcement:

1. Schedule A Actions Remain a Viable Enforcement Tool. The Northern District of Illinois continues to be a preferred jurisdiction for Schedule A patent enforcement, offering experienced judges, established procedural protocols, and a demonstrated willingness to grant TROs and default judgments in appropriate cases.
2. Statutory Damages Provide Recovery Without Full Discovery. When defendants default, plaintiffs are not required to prove actual damages through the normal evidentiary process. Statutory damages allow courts to impose meaningful financial consequences even where financial records of infringement are inaccessible.
3. TRO Mechanisms Remain Effective. The early TRO, supported by the surety bond, exemplifies how plaintiffs in these cases use preliminary relief to prevent asset dissipation before judgment — a critical tactical step when defendants may quickly liquidate infringing inventory or transfer funds.

Strategic Takeaways

For Patent Holders and Enforcement Counsel:

• Schedule A filings with early TRO motions create maximum enforcement leverage before defendants can disappear.
• Statutory damages provisions reduce evidentiary burdens when actual sales figures are unavailable.
• Illinois Northern District remains a strategically favorable forum.

For Accused Infringers:

• Failure to respond to federal litigation does not make the case go away — it guarantees an adverse judgment.
• Even defendants operating anonymously online are subject to service, jurisdiction, and enforceable court orders.

For R&D and Product Teams:

• Companies distributing products through third-party online marketplaces face patent enforcement exposure even when operating under marketplace seller agreements.
• Freedom-to-operate (FTO) analysis should include review of patent portfolios held by both individual inventors and small corporate entities — not just large portfolio holders.

Industry and Competitive Implications

The Diedrichsen v. Schedule A Defendants case reflects a broader enforcement trend in which individual inventors and smaller IP holding entities leverage the federal court system — and particularly the Northern District of Illinois — to pursue online marketplace infringers at scale.

This enforcement model has significant implications across multiple sectors:

• E-commerce platforms and third-party sellers face increasing exposure to coordinated Schedule A actions, particularly where products are commoditized and easily replicated.
• IP portfolio holders — including individual inventors — are increasingly partnering with specialized enforcement firms to monetize patents through litigation campaigns against online infringers.
• In-house IP counsel at consumer product companies must evaluate marketplace distribution strategies with patent risk in mind, including the conduct of sellers within their distribution networks.

The involvement of Dickinson Wright PLLC alongside Bishop Diehl & Lee, Ltd. suggests a well-resourced enforcement effort, indicating that plaintiffs in this case treated the litigation as part of a deliberate IP monetization strategy rather than an isolated dispute.

Frequently Asked Questions

What was the basis for default judgment in Diedrichsen v. Schedule A Defendants (1:24-cv-02773)?

The court granted default judgment because the defendants failed to answer or appear in the litigation following proper service, allowing the court to accept the infringement allegations as true and award statutory damages.

What is a Schedule A patent infringement case?

A Schedule A case is a patent (or trademark/copyright) enforcement action filed against multiple anonymous or pseudonymous defendants — typically online sellers — identified on an attached schedule rather than named individually in the caption.

Why is the Northern District of Illinois a common venue for Schedule A patent cases?

The district has developed extensive procedural experience with Schedule A enforcement actions, including established practices for TRO issuance, anonymous defendant service, and asset-freezing orders, making it a strategically preferred forum.

Case Reference: Diedrichsen et al. v. Schedule A Defendants, Case No. 1:24-cv-02773, U.S. District Court for the Northern District of Illinois (Judge Franklin U. Valderrama). Case closed November 13, 2025.

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